Skip to main content
Medium reported severity Lawsuit Dismissed

Oregon federal court dismisses family plaintiffs' claims and fines their lawyer after briefs cited 15 nonexistent cases it attributes to generative AI misuse

On 12 December 2025 the U.S. District Court for the District of Oregon dismissed with prejudice the claims of plaintiffs in a family dispute over their late mother's estate and family property, as a sanction for what the court called their misuse of generative artificial intelligence, and found their continual violations of the court's Local Rules an additional basis for the dismissal. Three of the plaintiffs' summary-judgment briefs cited fifteen nonexistent cases and fabricated quotations attributed to eight real authorities. The plaintiffs had said the inaccurate citations came from reliance on an automated legal citation tool. The court found that the plaintiffs shared responsibility with their lead lawyer and that one plaintiff, a frequent self-represented litigant, was likely the person who used AI to draft the briefs. It struck the briefs, ordered the lead lawyer to pay $15,500 to the court and awarded the defendants their fees. In March 2026 it set those fees at $94,704.38, ordering the lead lawyer to pay 85% and local counsel 15%. In June 2026 it denied the plaintiffs' motion to reconsider a later ruling for the defendants on a counterclaim.

AI system
Unidentified AI drafting tool
Occurred
31 Jan 2025 to 12 Dec 2025
Reported
12 December 2025
Event location
United States
What the AI did
Communicated with the person · Informed a human decision about the person
Reported harm
Legal HarmProfessional HarmFinancial Loss
Whose AI use
Their own AI use · Someone else’s AI use
Setting
Justice · Relationships
Evidence
AI involvement supported · Causal attribution established · 3 sources, 1 underlying account
6 claims: 6 documented. 4 open questions
People reported harmed
At least 3 people

AI system as recorded: Generative AI used to draft summary-judgment briefs, according to the court; the plaintiffs described it as an automated legal citation tool. No product is named in the orders

What Happened

The briefs. In cross-motions for summary judgment filed between January and May 2025, the plaintiffs filed three briefs that, the court found, cited fifteen nonexistent cases and attributed fabricated quotations to eight real authorities. The defendants pointed out the nonexistent cases in April 2025 and suggested they were perhaps hallucinated by AI. The plaintiffs later said the inaccurate citations were inadvertent and resulted from reliance on an automated legal citation tool, and they did not explain who drafted the briefs.

The finding. In its 12 December 2025 order the court called the case a notorious outlier among AI-misuse sanctions cases. It found that the plaintiffs shared responsibility with their lead lawyer, and that the defendants' unrebutted evidence showed one plaintiff, a serial self-represented litigator, was likely the person responsible for using AI to draft the briefs.

The sanctions. The court struck the briefs without leave to refile, fined the lead lawyer $15,500, awarded the defendants their fees and dismissed the plaintiffs' claims with prejudice. In March 2026 it apportioned $94,704.38 in fees between the two lawyers. In June 2026 it denied reconsideration of a later order granting the defendants specific performance of an inheritance contract on a counterclaim.

Reported harm

According to the court's orders, the plaintiffs' claims were dismissed with prejudice because their briefs cited nonexistent cases and fabricated quotations that the court attributes to misuse of generative AI, which it found one plaintiff likely used to draft them; the lead lawyer was fined $15,500 and the two lawyers were ordered to pay $94,704.38 in fees.

Outcome

Resolved

U.S. District Court for the District of Oregon, case 1:21-cv-00157: Opinion and Order of 12 December 2025 (ECF 215) struck the plaintiffs' summary-judgment briefs and amended filings without leave to refile, ordered the lead lawyer to pay $15,500 to the Clerk, awarded the defendants reasonable fees and expenses, ordered local counsel to show cause, dismissed the plaintiffs' claims with prejudice and sent the order to the Oregon State Bar. Opinion and Order of 23 March 2026 (ECF 225) found fees of $94,704.38 reasonable and ordered local counsel to pay 15% ($14,205.66) and the lead lawyer 85% ($80,498.72). Opinion and Order of 22 June 2026 (ECF 233) denied the plaintiffs' motion to reconsider the court's grant of the defendants' unopposed motion for partial summary judgment on a breach-of-contract counterclaim, which ordered specific performance of an inheritance contract. Whether the fines and fees were paid, and any bar outcome, are not established in the inspected orders.

What remains unknown

  • Which AI tool was used; the orders name none.
  • Who drafted the briefs: the court's finding is one of likelihood, and the plaintiffs gave no explanation.
  • Whether the fine and fees were paid, and the outcome of the order sent to the Oregon State Bar and of a later show-cause order to the lead lawyer.
  • Whether the counterclaim ruling was affected by the striking of the plaintiffs' briefs.

What the evidence supports

AI involvement: supported. The court's 12 December 2025 order describes the sanctions as being for the plaintiffs' misuse of generative artificial intelligence, finds that three briefs cited fifteen nonexistent cases and fabricated quotations, records the plaintiffs' statement that the citations resulted from reliance on an automated legal citation tool, and finds that one plaintiff was likely the person who used AI to draft the briefs (communicated_with). The AI output reached the court in those briefs, and the court dismissed the plaintiffs' claims and sanctioned their lawyers because of it (informed_decision_about). No product is named.

6 claims: 6 documented. What the statuses mean

Documented The plaintiffs filed three summary-judgment briefs citing fifteen nonexistent cases and fabricated quotations attributed to eight real authorities, and the court framed its sanctions as being for the plaintiffs' misuse of generative artificial intelligence.

Causal attribution. The court's own findings.

  • storage.courtlistener.com(opens in new tab) supports · English
    'The issue before the Court is the appropriate sanctions for Plaintiffs' misuse of generative artificial intelligence'; 'Plaintiffs filed three briefs containing citations to fifteen non-existent cases and fabricated quotations falsely attributed to eight legitimate authorities'
Documented The plaintiffs told the court the inaccurate citations were inadvertent and resulted from reliance on an automated legal citation tool.

Causal attribution. The plaintiffs' filing as quoted by the court.

Documented The court found that the plaintiffs shared responsibility with their lead lawyer and that one plaintiff, a serial self-represented litigator, was likely the person responsible for using AI to draft the briefs.

Causal attribution. A court finding of likelihood on unrebutted circumstantial evidence; the drafter's AI use is not otherwise established.

  • storage.courtlistener.com(opens in new tab) supports · English
    'The Court finds that Plaintiffs share responsibility with'; 'for the submission of fifteen non-existent cases and eight fabricated quotations'; 'is a serial self-represented litigator who was likely the person responsible for using artificial intelligence to draft the summary judgment briefs in this case'
Documented The court struck the briefs without leave to refile, ordered the lead lawyer to pay $15,500 to the Clerk, awarded the defendants reasonable fees and dismissed the plaintiffs' claims with prejudice; it found the plaintiffs' continual violations of the Local Rules an additional basis for that dismissal.

Causal attribution. Established by the order.

  • storage.courtlistener.com(opens in new tab) supports · English
    'STRICKEN without leave to refile'; 'to pay the Clerk of the Court $15,500 within 30'; 'Defendants are entitled to an award of reasonable attorney' ; 'Plaintiffs' claims are DISMISSED with'; 'Local Rules provides an additional basis for terminating sanctions against Plaintiffs' claims.'
Documented In March 2026 the court found fees of $94,704.38 reasonable and ordered local counsel to pay 15% ($14,205.66) and the lead lawyer 85% ($80,498.72).

Causal attribution. Established by the fees order.

  • storage.courtlistener.com(opens in new tab) supports · English
    'finds the requested amount of $94,704.38 reasonable'; 'is ORDERED to pay Defendants 15% of that award, $14,205.66'; 'pay Defendants the remaining 85%'; '$80,498.72 within thirty (30) days'
Documented In June 2026 the court denied the plaintiffs' motion to reconsider its grant of the defendants' unopposed motion for partial summary judgment, which had awarded specific performance of an inheritance contract on a breach-of-contract counterclaim.

Causal attribution. Established by the reconsideration order; the orders do not say the counterclaim outcome resulted from the AI sanction.

  • storage.courtlistener.com(opens in new tab) supports · English
    'Defendants' unopposed Motion for Partial Summary'; 'summary judgment on their eighth counterclaim for breach of contract and ordered specific performance of the inheritance contract'; 'Plaintiffs' Motion for Reconsideration (ECF No. 228) is DENIED.'

Sources

3 sources inspected, from 1 underlying account. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

Read in full in English by the research agent (an AI) on 2026-10-15 from CourtListener RECAP storage (HTTP 200, text extracted with pdftotext); no translation was needed. Applies to s1.

Read in English by the research agent (an AI) on 2026-10-15 from CourtListener RECAP storage (HTTP 200, pdftotext); the background and fee-allocation sections were inspected. Applies to s2.

Read in English by the research agent (an AI) on 2026-10-15 from CourtListener RECAP storage (HTTP 200, pdftotext); five-page order read in full. Applies to s3.

Event countries: United States. Affected-person countries: Unknown. Court countries: United States.

The briefs were filed in and the sanctions imposed by the U.S. District Court for the District of Oregon. Where the briefs were drafted and where the parties live are not used.

Reviewed for publication 2026-10-15: Published because the court's own orders establish that it dismissed the family plaintiffs' claims with prejudice and sanctioned their lawyers for briefs citing nonexistent cases and fabricated quotations, which the court attributes to the plaintiffs' misuse of generative AI and finds one plaintiff likely drafted with AI. The three orders were read.

People described

Family plaintiffs in a federal civil case over their late mother's estate and family property, whose claims were dismissed with prejudice; the court found one of them likely drafted the briefs with AI. Their lead lawyer, fined and ordered to pay most of the defendants' fees, and their local counsel, ordered to pay the rest. The plaintiffs and lawyers are private people and are not named here.

People reported harmed in this case

At least 3 people

0 AI participants · 3 other people harmed

Additional affected people are described without a reliable count.

Three people counted from the orders: the individual plaintiff whose claims were dismissed (found likely to have drafted the briefs with AI, so that AI use is a finding of likelihood and she is not counted as an established user), the lead lawyer (fined and ordered to pay 85% of fees) and local counsel (ordered to pay 15% of fees). The estate whose claim was also dismissed has beneficiaries the orders do not count; the LLC plaintiff is not a person.

Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.

Cite this case

Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.

APA

NOPE. (2026). Oregon federal court dismisses family plaintiffs' claims and fines their lawyer after briefs cited 15 nonexistent cases it attributes to generative AI misuse. AI incidents. https://nope.net/incidents/2025-oregon-federal-court-dismisses-family-plaintiffs-claims-after-briefs-with-ai-fabricated-citations

BibTeX

@misc{2025_oregon_federal_court_dismisses_family_plaintiffs_claims_after_briefs_with_ai_fabricated_citations,
  title = {Oregon federal court dismisses family plaintiffs' claims and fines their lawyer after briefs cited 15 nonexistent cases it attributes to generative AI misuse},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2025-oregon-federal-court-dismisses-family-plaintiffs-claims-after-briefs-with-ai-fabricated-citations}
}

Related cases

Medium Unidentified AI research tool

Alabama Supreme Court dismisses two siblings' family-trust appeal as a sanction after their lawyer admits using AI that produced fake citations

On 24 April 2026 the Supreme Court of Alabama dismissed an appeal by two siblings in a family dispute over living trusts because their lawyer, W. Perry Hall, had filed briefs in which most of the legal authorities were misquoted or did not exist. The court said they appeared to be AI hallucinations, and at a show-cause hearing in February 2026 Hall admitted that many authorities did not exist and that he had improperly used AI to obtain them. The court ordered Hall to pay the opposing party's fees and costs of $17,200 and double appeal costs, barred him from filing in the court without a co-signing attorney and referred him to the Alabama State Bar. It said the dismissal was imposed as a sanction because of the particularly egregious facts. One justice, concurring in part and dissenting in part, objected to dismissing the appeal as a sanction for the lawyer's conduct but would have affirmed the judgment against the clients on the merits.

Low Unidentified AI drafting tool

Paraíba, Brazil: judge fines a lawyer R$32,800 over hidden AI commands in a petition, G1 reports; state bar later suspends two lawyers in such cases

A judge of the 5th Mixed Court of Sousa, Paraíba, found hidden instructions aimed at artificial intelligence tools spread over seven pages of a lawyer's motion for clarification in a public-competition case in June 2026, including an order to ignore impartiality and a note calling it a test of whether the judge used only AI to decide. The judge fined the lawyer two penalties of R$16,400 (R$32,800 in total) for bad-faith litigation and contempt of the court's dignity, and referred the case to the Paraíba bar (OAB-PB) and the state prosecutors, G1 reports. The defence said the commands were not inserted deliberately and blamed an error in exporting a file prepared with AI support. An appeal judge refused to suspend the fines on 30 June, the trial judge kept them on reconsideration, and in July, G1 reports, the OAB-PB preventively suspended two lawyers after opening procedures into two hidden-command cases, one of them the Sousa case.

Low Unidentified AI drafting tool

Colorado federal court fines two MyPillow defence lawyers $3,000 each over a brief with fabricated citations; lead counsel had admitted running it through AI

In the defamation case Coomer v. Lindell in the US District Court for the District of Colorado, a brief that lawyers for Mike Lindell and MyPillow filed on 25 February 2025 contained nearly thirty defective citations, including citations of cases that do not exist. At a conference on 21 April 2025 lead counsel Christopher Kachouroff told Judge Nina Y. Wang that he had drafted the motion and then 'ran it through AI' and had not personally checked the citations. Counsel later said a wrong draft had been filed by mistake; the court was not persuaded. On 7 July 2025 the court found that he and co-counsel Jennifer DeMaster had violated Rule 11 and fined each $3,000 (Kachouroff jointly with his law firm). The court did not sanction Lindell or his companies.

Low Unidentified AI drafting tool

Nebraska Supreme Court strikes a self-represented appellant's brief over fabricated citations from admitted AI use; plain-error review only (2 Oct 2026)

On 2 October 2026 the Nebraska Supreme Court struck the appellate brief of a self-represented party appealing a contempt order in his divorce case because the brief contained numerous citations to fictitious cases and misstatements of law, which the court said were the result of his admitted use of generative artificial intelligence. The court held that self-represented litigants are held to the same standard as attorneys and that submitting a brief relying on nonexistent authority is an abuse of the judicial process worthy of sanctions. Citing the novelty of the issue for self-represented parties, it stopped short of dismissing the appeal and reviewed only for plain error, finding none and affirming the district court's contempt finding, its sanction of 90 days' incarceration with purge conditions, a temporary reduction of his parenting time and an attorney-fee award. The court warned that in future cases dismissal of the appeal may follow. The opinion does not name the AI tool.

If you or someone you know is struggling, free and confidential support is available. Find a helpline near you at Signpost.